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“on-money”

Cash Credits & Unexplained ItemsSection 69BSection 69B1,574 judgments

The decision most relied on for on-money is CIT v. President Industries (258 ITR 654), cited in 471 judgments on BharatTax.

Leading authorities on on-money

CIT v. President Industries
258 ITR 654 · 2002 · High Court
471
citing judgments

When books of account are rejected and unaccounted sales or receipts are discovered, the income addition is restricted to the net profit element embedded in these undisclosed transactions, not the entire sale proceeds or receipts, especially if corresponding purchases are not proven to be outside the books.

CIT v. Balchand Ajit Kumar
263 ITR 610 · 2003 · High Court
212
citing judgments

When making an addition for unaccounted receipts, on-money, or non-genuine purchases/sales, the addition should be restricted to the estimated profit element embedded in such transactions, rather than the entire gross amount, particularly when evidence of corresponding expenditure is incomplete. This estimation often involves applying a net profit rate.

CIT v. Girish Chaudhary
296 ITR 619 · 2008 · High Court
175
citing judgments

Additions to income cannot be made solely based on "dumb documents" or vague loose papers seized during a search that merely indicate rates without specific corroborative material linking them to the assessee's unaccounted transactions. The presumption under Section 292C may not apply to such documents.

Principal Commissioner Income Tax, Central-2 v. Umesh Ishrani
108 Taxmann.com 437 · 2019 · High Court
168
citing judgments

An addition to income cannot be made solely based on entries in loose papers found during a search without conducting any independent inquiry or verification from the alleged seller or developer. Reliance solely on digital records without corroborative evidence is insufficient for an addition.

CIT v. Maulikkumar K. Shah
307 ITR 137 · 2008 · High Court
166
citing judgments

Additions on account of on-money receipts cannot be justified solely based on loose papers or 'sauda-chithis' without evidence of actual payment or a clear indication of a completed transaction within those documents.

CIT v. Gurubachhan Singh J. Juneja
302 ITR 63 · 2008 · High Court
147
citing judgments

When unaccounted receipts or suppressed sales are detected and books of account are rejected under Section 145(3), additions to income must be restricted to the profit element embedded in such transactions, not the entire transaction value. This profit element is to be estimated by considering the assessee's regular profit ratio as per books of account.

CIT v. Shivakami Co. (P.) Ltd.
159 ITR 71 · 1986 · Supreme Court
133
citing judgments

The burden of proving an understatement of consideration or the receipt of 'on-money' lies solely with the Revenue, which must provide cogent evidence of actual receipt of higher consideration, beyond mere estimates or suspicion. Additions cannot be made based on assumptions like differences from circle rates without such evidence.

Man Mohan Sadani v. CIT
304 ITR 52 · 2008 · High Court
132
citing judgments

When assessing income from undisclosed or unrecorded sales, the entire sale proceeds cannot be added to the assessee's income; instead, only the net profit embedded in such unaccounted sales, determined by applying the assessee's net profit rate, should be taxed.

Judgments citing on-money

DCIT, Central Circle-4, Surat vs. Ekkta Devlopers, Mumbai

In the result, both appeals are dismissed

ITA 577/SRT/2024[2015-16]Status: DisposedITAT Surat07 Aug 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.576 & 577/Srt/2024 (Ays:2014-15 & 2015-16) (Hybrid Hearing) Dcit, Vs. M/S Ekkta Developers, Central Circle – 4, B-702, Business Point, S. V. Road, Surat Andheri (W), Mumbai - 400058 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefe5374R (Appellant) (Respondent) Co Nos.38 & 37/Srt/2024 (Arising Out Of Ita Nos.576 & 577/Srt/2024) (Ays: 2014-15 & 2015-16) M/S Ekkta Developers, Vs. Dcit, B-702, Business Point, S. V. Road, Central Circle – 4, Andheri (W), Mumbai - 400058 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefj3969P (Appellant) (Respondent) Appellant By Shri Ravi Kant Gupta, Cit-Dr Respondent By Shri Ramesh Malpani, Ca Date Of Hearing 30/07/2025 Date Of Pronouncement 07/08/2025

Section 133ASection 143(1)Section 147Section 148Section 292CSection 69BSection 69C

erred in deleting the addition of 26,17,66,223/- made by the AO on account of on-money payment for purchase of land u/s 69B of the I.T. Act despite the facts that addition has been made on the basis of incriminating details/document recovered during the survey proceedings ... erred in deleting the addition of ₹26,17,66,223/- made by the AO on account of on-money payment for purchase of land u/s 69B of the I.T. Act observing that in absence of any corroborative evidences or finding of actual payments of cash in land transaction, the addition